ML20237J740
| ML20237J740 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 08/13/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| SL-2900, NUDOCS 8708180313 | |
| Download: ML20237J740 (20) | |
Text
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.L Gaorgia Power Company i
.3'
- 333 Piedmont Avenue
- Atlanta. Georgia 30308
- Telephone 404 526-6526 Malling Address:
Fbst Office Box 4545 -
' Atlanta, Georgia 30302 Georgia Power L T. Gucws
'#* I'*I'd" NAN SV**
Manager Nuclear Safety and Ucensing 1'
l SL-2900 1530C X7GJ17-H120 August 13, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C.
20555 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 RESPONSE TO INSPECTION REPORT 87-12 Gentlemen:
In response to your letter of July 15, 1987, and in accordance with the provisions of 10 CFR Section 2.201, Georgia Power Company (GPC) is providing the enclosed response to the Notice of Violation associated with inspections conducted at Plant Hatch during the period of May
.27-July 3, 1987.
A transcrip' tion of the NRC Notice of Violation 'is provided as.
GPC's response is provided as Enclosure 2.
Should you have any questions in this regard, please contact this office at any time.
Sincerely, g4 r-L. T. Gucwa 1
-LGB/lc
Enclosures:
- 1. NRC Notice of Violation
- 2. Georgia Power Company Response i
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Georgia Power n U. S. Nuclear Regulatory Commission August 13, 1987 Page Two i
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Georgia Power Comoany Mr. J. P. O'Reilly, Sr. Vice President - Nuclear Operations Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Regulatorv Commission. Washington. D. C.
Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch i
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l ENCLOSURE 1 l
PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 NRC NOTICE OF VIOLATION 87-12 l
NRC NOTICE OF VIOLATION 87-12-01 A.
Technical Specification 6.8.1.c requires the licensee to establish and implement procedures for the conduct of surveillance and test activities of safety related-equipment.
Technical.- Specification 6.8.1.a requires the licensee to establish, implement and maintain ' wri tten procedures covering the applicable activities in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix
- A. of Regulatory Guide 1.33 recommends establishment of procedures for'the operation of the shutdown cooling system.
Contrary to the above; 1.
The licensee failed to provide adequate procedures for the performance of excess flow check valve surveillance testing on April 18, 1987.
Improper -jumpering and link operating resulted in inadvertent isolation of the High Pressure Coolant Injection and Reactor Core Isolation Cooling systems.
2.
Licensee procedures used to fili the "B" loop of the Residual Heat Removal /.RHR) system in the shutdown cooling mode on April 22, 1987, were inadequate.
Inadequate RHR filling instructions resulted in draining of the reactor vessel to the plus ten inch level (approximately 15.5 feet above the active fuel).
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ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-12 3.
The licensee failed to provide adequate procedures for the performance of operability l
testing on valve 1E11-F078A, Service Water Intertie Valve, on June 15, 1987.
In the absence l
of written instructions on how to relieve differential pressure across the valve prior to testing, the reactor operator selected and opened l
two RHR system valves to relieve the differential pressure.
Opening of these valves created a flow path from the reactor vessel to the suppression pool resulting in a rapid loss of reactor vessel inventory to the plus ten inch level.
This is a Severity Level IV violation (Supplement I).
NRC NOTICE OF VIOLATION 87-12-02 B.
Technical Specification 6.8.1.a requires the licensee to establish, implement and maintain written procedures covering the applicable activities in Appendix A
of Regulatory Guide 1.33, Revision 2, February 1978. Appendix l
A of Regulatory Guide 1.33 recommends establishment of procedures for equipment control (e.g.
locking and tagging).
Licensee's procedure 30AC-0PS-001-0S establishes controls for equipment clearances and tags. This procedure requires that Operations issue a clearance for maintenance isolation.
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k Georgia Power n ENCLOSURE 1 (Continued)
NRC NOTICE OF VIOLATION 87-12 Contrary to the above, on June 20-21,
- 1987, licensee personnel performing maintenance on drywell cooler 1T47-B008A, failed to comply with the requirements of 30AC-0PS-001-0S.
Air operated valves supplying cooling water to the cooler were jacked closed with no clearance issued.
Upon completion of the maintenance, the valves were not returned to normal lineup.
This resulted in the cooler being left inadvertently isolated and higher than expected drywell temperatures upon return to power operations.
This is a Severity Level V violation (Supplement I).
1530C El-3 8/13/87 SL-2900 700775
k Georgia Power h ENCLOSURE 2 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 M SPONSE TO WRC NOTICE OF VIOLATION For ease of comparison, the violation cited as Violation A is numbered 87-12-01.
The violation cited as Violation B in the Notice of Violation is numbered 87-12-02.
Each of the two violations will be discussed separately.
ESPONSE TO VIOLATION 50-321/87-12-01 Admission or denial of violation:
The violation occurred as cited in the Notice of Violation.
In the Notice of Violation, three examples were cited.
The first involved an Excess Flow Check Valve (EFCV) surveillance procedure.
This event occurred on April 18, 1987.
The second and third examples involved reductions in reactor vessel water levels.
The second example occurred on April 22, 1987 and the third example occurred on June 15, 1987.
Each example will be discussed separately.
Reason for the violation:
1.
EFCV Surveillance Procedure:
The event occurred due to an inadequate procedure (Reactor Coolant Instrumentation Lines Excess Flow Check Valve Operability procedure 57SV-SUV-004-1S).
The procedure, Table 1,
lists the jumpers that are required to be installed and the links that are required to be opened in order to correctly perform the procedure.
This table contained errors, in that all applicable jumpers and links were not listed in the table.
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Georgia Power n ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION Specifically, a jumper that was installed for the High Pressure Coolant Injection (HPCI) EFCV serves no purpose in preventing the isolation.
In the case of the Reactor Core Isolation Cooling (RCIC) EFCV, the procedure had only one half of the isolation logic disabled (the logic for the high steam line flow signal was not disabled).
These errors were introduced into the procedure as a result of an inadequate review of design drawings incorporating Analog Transmitter Trip System (ATTS) modifications.
It is to be noted that the defective procedure had not yet gone through the full Procedures Upgrade Program (PUP) review and upgrade process.
Additionally, this was the first performance of this procedure since the ATTS modifications were completed on Unit 1.
2.
Reduction in vessel inventory on 4/22/87:
This event was caused by a
procedural inadequacy.
Plant procedure 34S0-Ell-010-1S (Residual Heat Removal System) was inadequate in that the method of determining when the Residual Heat Removal (RHR) Shutdown Cooling (SDC) piping was full was not conclusive.
A contributing factor in this event was that valve IPil-F020B (a condensate transfer system supply valve which supplies water to two RHR valves in the RHR system) was closed.
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. Georgia Power h ENCLOSURE 2 (Continued) l-RESPONSE TO NRC NOTICE OF VIOLATION i
3.
Reduction in vessel inventory on 6/15/87:
This event was the result of. cognitive personnel error.
When a licensed plant operator opened two RHR system valves in order to reduce the differential pressure across a RHR to RHR Service Hater (RHRSH) check valve, he did not realize that this would create a flow path by which reactor vessel inventory could be drained to the torus (suppression 1
pool).
Additionally, the opening of the two RHR system valves was not part of any of the procedures that were in r
progress at the time of the event.
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Corrective steps which have been taken and the results achieved:
The corrective action discussion will include not only a general discussion of the methodology and adequacy of the overall procedures development / upgrade program / process, but also the particular corrective actions for each one of the cited examples.
The Procedure Upgrade Program (PUP) at Plant Hatch is a long term program to correct identified deficiencies in existing plant procedures.
The PUP is also a long term program to ensure that newly developed plant procedures are technically adequate and incorporate all license conditions.
Details of the PUP have been presented to NRC - NRR and NRC - Region II personnel.
The procedure revision / review / development process is documented in plant procedure 10AC-MGR-003-0S (Preparation and Control
.of Protadures).
One of the strongest points of the existing procedures development program is the validation process.
The validation procass is not only a mechanical process to ensure that procedures are technically adequate, but it also involves various levels of the plant staff.
The involved plant personnel include:
department
- managers, procedure
- sponsors, procedure
- writers, and technical reviewers /validators.
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k Georgia Power h ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION The department manager is responsible for approving the procedure validation requirements.
The procedure sponsor is a knowledgeable senior person who reviews the Technical Review Checklist to verify all technical items dre included and are correct.
The procedure writer is a technically knowledgeable person with qualifications sufficient to prepare or revise a comprehensive user oriented -
procedure.
The procedure writer performs the necessary research to-develop a procedure that is technically correct.
This includes walking the system down (if practical), conferring with responsible plant personnel as required-, and reviewing the appropriate technical documents to ensure all necessary commitments and requirements are met.
The. technical. reviewer /validator performs specialized tasks.
.This person is not the writer.
The validator is competent in the disciplines addressed in a
procedure, whether technical. or organizational,- and generally has qualifications equal to or higher than that of the procedure writer.
The validator not only recommends the validation me', hod to be used with each procedure but also validates the procedure as directed by the department manager.
. Additionally, the validator maintains a record for each procedure indicating the type of validation used for each section of the I
procedure.
This documentation is maintained until the validation is complete and the procedure is given final approval by the plant manager.
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION The validation process is the mechanism by which Plant Hatch personnel verify that procedures will. perform their intended functions.
New procedures and procedures which have been upgraded or extensive'y changed must be validated.
The validation will be by actual-performance of. the procedure where practical.
As a minimum, (when actual or simulator performance of the procedure is not practical), a validation will include a talkthrough and where practical, a walkdown involving the most knowledgeable department representative.
This person is determined by the department manager.
There are four approved methods of performing the validation of a procedure.
These are:
- 1) actual or simulator performance, 2)
' talkthrough, 3) walkdown, and 4) comparison with an approved similar procedure.
The preferred method of validating a procedure is-by actual performance.
Each of these validation methodologies are further discussed below.
Whea practical, the validation of a procedure will be done by actual performance of the procedure.
The actual performance (either in the plant or on the simulator) is documented on a procedure checklist.
When actual or simulator performance is used to validate a procedure, personnel are required to document any comments regarding the procedure on the procedure checklist.
The Plant Review Board (PRB) reviews the procedure data and any validation comments.
The PRB review verifies that the procedure requirements were satisfactorily met.
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION In general, most sections of the following procedure types are validated by performance:
- 1) General Operating, 2) System Operating,
- 3) Surveillance, 4) Maintenance, 5) Instrument and Control (I&C), 6)
Engineering, 7) Health Physics, and 8) Chemistry.
When talkthroughs are used to validate a procedure, the personnel performing the validatio7. '.. ave a great deal of responsibility placed on them.
This occurs necause the effectiveness of the procedure depends solely on the person's expertise and judgement.
Some procedures,- particularly in the Operations Departrant, have the objective of bringing the plant from one condition to another.
The choice of a method of accomplishing the procedure objective needs to be based on the ease, quickness and safety of the method used.
Oftentimes, when talkthroughs are performed to validate a procedure, the validation is conducted by obtaining concurrence from at least one additional qualified individual.
This is accompanied where practical, by a physical walkdown of the procedure to confirm the accuracy of plant equipment locations, equipment numbers 'and other data.
As in the case of actual performance to accomplish the procedure validation, a checklist is used to document the findings of the validation.
Walkdowns are used as a check to confirm that physical devices in the plant are identical to the devices named in the procedure.
The walkdown also verifies that it is physically possible to perform each step in the procedure.
A walkdown will be used to validate specific tasks (such as valve line ups) that are associated with clearly j
identified pieces of equipment.
Persons who perform the walkdown are required to go to the area or device where each procedure step is required to be conducted.
The validator uses a checklist to confirm i
that each individual procedure step is correct and can be performed J
as written.
As in other forms of validation, the comments from this j
validation process are documented.
These comments are forwarded to
{
the procedure writer for resolution.
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION Talkthroughs and walkdowns are used to validate the following types of ' procedures:~ Administrative Control,and 5) portions of other
- 1) Abnormal Operating, 2) Annunciator Response, 3)
Security, 4) procedures where it is impractical to validate the procedurt. by actual performance.
The last form of validation is the compariso.'. ith an approved w
similar procedure.
This can be' used with new procedures or with individual procedure steps.
This form of procedure validation is performed in conjunction with a physical walkdown of the procedure.
The-validator will compare the new procedure to the already existing approved procedure.
If the steps are identical - and are in the identical order, and the validator knows that the existing' procedure has been successfully performed, those steps in the new procedure can be considered as validated.
The validator has the option of performing the existing procedure with the new procedure in hand.
This allows for validation of steps which are similar or give additional information.
However, if the procedure steps are not ide.ntical or the steps are in a di fferent order and it is not possible to perform the existing procedure with the new procedure in hand, the validation must N_QI be performed by comparison only.
This brief overview of the procedure validation process at Plant Hatch is the long term corrective action to prevent recurrence of events caused by procedure inadequacies.
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Georgia Power 1 ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION In light of the events described in the Notice of Violation, Gi.orgia-Power Company (GPC) conducted a review of the existing PUP efforts.
As of July, 1987,.1171 procedures have been upgraded,' validated and.
are in use in the plant.
Discounting procedures which were revised due to Design Change Requests (DCRs) or similar technical changes, _34 upgraded procedures have been revised over the past 18 months.
Most of these_ revisions relate to additions of
- notes, cautions, identification numbers, additional manufacturer's recommendations, and corrections 'of-referenced step numbers.
Detailed monitoring of the upgrade program will continue throughout the program with L
adjustments made as necessary to improve quality.
l While the above corrective actions are for the long term aspect of upgrading procedures, GPC also implemented corrective actions to correct the cited specific deficiencies stated in the Notice of Violation.
The following corrective actions were performed for each of the cited examples:
1.
EFCV Surveillance Procedure:
a.
Investigating the unanticipated valve closures for both the HPCI and RCIC systems.
b.
Implementing temporary changes to plant surveillance procedure 57SV-SUV-004-1S.
This occurred on 4/21/87.
c.
Performing the modifled surveillance procedure and verifying that the surveillance results were satisfactory.
This occurred on 4/24/87, 1530C' E2-8 8/13/87 SL-2900 L
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION d.
Implementing a procedure revision request to revise the surveillance procedure.
This will include performing a full PUP review of the procedure and will include all aspects of a PUP upgrade including validation and verification that the procedure is technically adequate to perform the required surveill&nce.
The validation process includes technical verification of all links opened or closed and all jumpers installed and removed.
Additionally, the procedure will be walked through to ensure technical adequacy.
The procedure revision will be in effect prior to the next scheduled performance of the procedure.
e.
Veri fying that the Unit 2 procedure could be performed successfully and thus contained no similar errors.
2.
Reduction in vessel inventory on 4/22/87:
a.
On 4/22/87, licensed personnel restored reactor level to +32 inches referenced to instrument zero. All protective action signals were reset.
b.
On 4/23/87 the "B" RHR loop was placed in the SDC mode of operation.
The Unit I
reactor was brought to a cold shutdown condition for the scheduled refueling outage.
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION c.
The Unit 1 and Unit 2 Residual Heat Removal System procedures (34S0-E11-010-1S.
and 34S0-E11-010-2S) will be revised to include a-more positive method of verifying that the RHR piping is filled prior to placing the system in the SDC mode of operation.
The procedure revisions will be in place by approximately 9/1/87.
d.
As an intermediate corrective action until the procedures are
- revised, plant operations management placed an information tag on the 1
respective control switches for the SDC suction pathway valves (1 Ell-F009 [ Unit 1] and 2E11-F009
[ Unit 2]).
This tag requires operations management approval prior to opening the valve in order to establish the SDC mode of operation of the RHR system.
3.
Reduction in vessel inventory on 6/15/87:
a.
Operations personnel restored reactor vessel water level using the Control Rod Drive (CRD) system.
b.
The responsible licensed individual was counseled to be fully aware of the consequences of each action before he acts.
This occurred on 6/15/87.
c.
The event was discussed with operations personnel at the beginning of shift turnover meetings on 6/15/87.
The discussions continued in shift turnover meetings on 6/16/87 and 6/17/87.
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Georgia Power h ENCLOSURE 2.(Continued) i RESPONSE TO NRC NOTICE OF VIOLATION d.
Instrument and Control (I&C) personnel investigated the Primary Containment Isolation System valve. isolation to verify that all isolation functions were correct.
e.
A Request for Engineering Review (RER) was generated to investigate the. possibility of adding an interlock between the suction valves from the reactor vessel for each RHR loop and that RHR loop's discharge valves to the torus.
These would prevent these valves from being opened in error at the same time.
f.
The plant operations department assigned a Shift Test Coordinator (STC) to the control room to coordinate the performance of Logic System Functional Tests, surveillance and maintenance activities., This temporary position remained in effect for the duration of the recently completed Unit 1 refueling outage.
This individual is a senior SR0 of the On Shift Operations Supervisor (OSOS) classification.
This classification of operations personnel is the highest and most responsible position classification of operations shift positions.
Corrective steos which will be taken to avoid further violations:
As previously stated in other sections of this response, the icng term corrective actions to detect, correct, and prevent procedure inadequacies is the PUP.
This program will continue in its efforts to upgrade existing plant procedures.
The validation process required by the PUP is ccntained in existing plant administrative control procedures and this process will be continued.
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ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION In addition to the above item, specific corrective actions will be performed, where applicable, to correct the tited deficiencies in the Notice of Violation. These include:
1.
EFCV Surveillance Procedure:
Immediate corrective actions were taken, as described above, which should preclude recurrence of the cited events.
2.
Reduction in vessel inventory on 4/22/87:
The Unit 1 and Unit 2
Residual Heat Removal System procedures (34S0-E11-010-lS and 34S0-E11-010-2S) will be revised to include a more positive method of verifying that the RHR piping is filled prior to placing the system in the SDC l
mode of operation.
The procedure revisions will be in i
place by approximately 9/1/87.
3.
Reduction in vessel inventory on 6/15/87:
Immediate corrective actions were taken. as described above, which should preclude recurrence of the cited events.
DAt.fLwhen full como11ance will be achieved;.
1.
EFCV Surveillance Procedure:
Full compliance was achieved on April 24, 1987.
2.
Reduction in vessel inventory on 4/22/87:
Full compliance was achievad on April 23, 1987.
3.
Reduction in vessel inventory on 6/15/87:
Full compliance was achieved on June 17, 1987.
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k Georgia Power n ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION RESPONSE-TO VIOLATION 50-321/87-12-02 Admission or denial of violation:
The violation occurred as cited in the Notice of Violation.
Reason for the violation:
The' violation occurred due to personnel error on. the part of both non-licensed maintenance personnel and licensed operations personnel-in that they failed to comply with the requirements of existing plant procedure 30AC-0PS-01-0S (Control of Equipment Clearances and Tags).
The -following is a summary of the sequence of events leading up to the cited violation.
On 6/18/87, while Unit 1 was in a scheduled refueling outage, a tube leak was identified in drywell cooler 1T47-8008A.
Maintenance Work Orders -(MHO) were generated to repair the leak and the cooler was.
properly removed from service (in accordance with clearance 1-87-1359) by closing the manual inlet valve (IP41-F018A) and the manual discharge valves (1P41-F055A and 1P41-F056A).
On 6/20/87, maintenance personnel began the planned work but were unable to repair the leak due to the fact that water was still flowing into the cooler.
This apparently occurred due to seat leakage pact inlet valve 1P41-F018A.
The responsible maintenance foreman and the operations shift supervisor discussed the situation and concluded that in-leakage could be stopped by closing Air Operated Valves (A0Vs) IP41-F045A and-1P41-F046A.
These valves are located between the manual inlet valve 1P41-F018A and the cooler unit IT47-B008A.
Operations personnel instructed the maintenance personnel to inform them of the actions necessary to fully isolate the cooler.
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I Georgia Power m ENCLOSURE 2 (Continued)
. RESPONSE TO NRC NOTICE OF VIOLATION Maintenance personnel jacked the air operated valves closed to control the water in-leakage and continued their repair efforts.
The information that the valves were jacked closed was not relayed to the operations personnel in the control room.
Accordingly, the decision to close valves 1P41-F045A and IP41-F046A was not documented in the Shift Supervisors log nor was any amendment made to the existing clearance which was controlling the work on the drywell cooler.
Cooler repairs were completed on 6/21/87 and operations personnel restored the clearance boundary valves I P41-F018A, 1 P41-F055A, and IP41-F056A to their normal positions- (open) when they removed clearance 1-87-1359.
The air operated isolation valves (1P41-F045A and IP41-F046A) remained isolated since they had not been included on the clearance restoration sheet.
Since these two. valves were still closed, drywell cooler 1T47-8008A was left inadvertently isolated and higher than expected dryvell temperatures occurred when the reactor was returned to power operation following the refueling outage on 6/27/87.
A reactor shutdown and drywell entry were required on 6/28/87 in order to reopen the closed drywell cooler isolation valves.
Unit
'I was returned to power operation on 6/29/87.
Corrective steos which have been taken and the results achieved:
As previously stated, A0Vs 1P41-F045A and 1P41-F046A were opened and drywell cooler 1T47-8008A was returned to service on 6/28/87.
Maintenance and Operations personnel involved in the decision to close the A0Vs without proper documentation were formally disciplined for their actions.
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Georgia Power h ENCLOSURE 2 (Continued)
RESPONSE TO NRC NOTICE OF VIOLATION On 6/30/87, the Plant Manager issued a memo to all plant personnel reiterating the requirement that equipment manipulations must be done in accordance with approved plant procedures.
Also, this event, along with 3aneral clearance and tagging requirements, was reviewed with maintenance personnel in their daily informal work assignment /information meetings.
Corrective steps which will be taken to avoid further violations:
Georgia Power believes that, had the existing administrative controls been followed, this event would not have occurred.
Consequently, no further corrective actions are planned beyond those listed above.
Date when full como11ance will be achieved:
Full compliance was achieved when valves 1P41-F045A and F046A were reopened on 6/28/87.
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